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FINDINGS OF FACT
We incorporate herein the findings of fact set forth in
Riggs Natl. Corp. & Subs. v. Commissioner, 107 T.C. 301 (1996)
(Riggs I), revd. and remanded 163 F.3d 1363 (D.C. Cir. 1999)
(Riggs II), and Riggs III by this reference. We also incorporate
herein the stipulations and exhibits in Riggs I and Riggs III by
this reference. For ease of understanding, we repeat those facts
set forth in Riggs I and Riggs III which we deem necessary to
clarify the supplemental findings set forth herein and the
ensuing opinion involving the issue for decision.
In Brazil, the Central Bank performed a number of
governmental functions in conjunction with Banco do Brazil,
including the unified management and operation of Brazil’s
monetary and financial system under what was known as the caixa
unico system.3 From 1965 through 1986, Banco do Brazil had four
primary functions: (1) A commercial bank, (2) a monetary
authority, (3) management control and distribution of currency,
and (4) responsibility for bank clearing. Further, like the
Central Bank, Banco do Brazil functioned as: (1) A lender of last
resort to public-sector entities, (2) a development bank
responsible for various subsidized credit programs of the
Brazilian Government, and (3) a fiscal authority that managed the
3Until the Central Bank was formed in 1965, Banco do Brazil
served as the country’s sole monetary authority.
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